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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Estate Planning

Date & Time
  • event Date

    Friday, January 19, 2024

  • schedule Time

    1:00 p.m. ET./10:00 a.m. PT

  • timer Program Length

    90 minutes

Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.

  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

$297.00
CLE
CPE
ALL

This CLE/CPE webinar will provide estate planners and advisers an in-depth analysis of domicile and residency considerations for business owners and their impact on estate and tax planning. The panel will discuss the challenges faced by business owners shifting residency from one state to another to maximize overall tax benefits and issues that arise when their business operations remain in the former state. The panel will also discuss tax issues, valuation challenges, succession, and mechanisms to ensure effective estate planning.

Faculty

Ian S. Horowitz
Of Counsel
Falcon Rappaport & Berkman LLP

Mr. Horowitz focuses his practice on estate, gift, federal income, generation-skipping transfer taxation and related business transactional matters. He provides counsel to businesses and individuals on entity formation, tax-efficient structures, and overall business strategies. Mr. Horowitz has extensive experience in preparing estate planning documents and implementing estate plans ranging from simple wills to complicated domestic and foreign trusts, for asset protection purposes, as well as drafting business transactional documents including purchase and sale agreements, limited liability operating agreements, and other corporate agreements. Mr. Horowitz has experience in international tax advising foreign clients on inbound business and real estate transactions, as well as counseling domestic businesses on outbound foreign business activities. He also works with non-resident aliens on pre-immigration planning.

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Matthew E. Foreman
Partner, Co-Chair Taxation Practice Group
Falcon Rappaport & Berkman LLP

Mr. Foreman co-chairs FRB’s Taxation Practice Group and advises businesses on the tax effects of a variety of corporate transactions, including taxable and tax-free reorganizations, mergers, sales, and acquisitions. He designs and implements tax-efficient structures for U.S.-based businesses to expand abroad and invest in foreign joint ventures. Mr. Foreman drafts tax memoranda and opinions on a variety of subjects, including tax-free reorganizations, tax-efficient return of capital to owners, Qualified Small Business stock, and various state pass-through entity taxes. He defends clients from audits from the IRS and various state tax agencies, including appealing audit determinations. Mr. Foreman advises clients on a variety of tax issues related to cryptocurrencies, including initial coin offerings (ICOs), taxability of staking and air drops, and the imposition of Sales and Use taxes on the issuance of non-fungible tokens (NFTs). He drafts tax portions of Operating and Shareholder Agreements for businesses in different industries. Mr. Foreman has extensive experience in a variety of SALT issues, especially New York State residency audits and state Sales and Use tax nexus issues post-Wayfair.

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Mary W. Browning
Member
Cole Schotz P.C.

Ms. Browning has practiced tax, trusts and estates law with her own characteristic blend of compassion, commitment and legal mastery for twenty years. She is a renowned and respected practitioner and lectures in the areas of trusts and estates, special needs planning, elder law planning, multistate tax issues and charitable gifting.

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Description

Domicile and tax residency can complicate estate planning for business owners requiring attorneys and advisers to consider complex tax laws and available planning tools. Estate planners for those seeking to relocate to a more tax friendly state must take measures to minimize taxes so that the business interest doesn't create issues for the estate and beneficiaries.

Effective estate planning for business owners maximizes the value of their business, minimizes taxes, and provides for the continuity of business succession. This involves an in-depth understanding of planning methods, legal nuances, and related issues such as business valuation challenges, the use of buy-sell agreements and trusts, tax considerations in succession planning, lifetime transfers, and other priority items.

High-income taxpayers relocating to low or no income tax states with active business operations and employees in the state they have left creates several estate planning and tax issues. This requires attorneys and advisers to have an in-depth understanding of the challenges stemming from business interests in estate planning and administration and techniques to minimize income, estate, and gift taxes.

Listen as our experienced panel provides a complete analysis of domicile and tax planning for business owners and key elements for shifting domicile from one state to another to maximize overall tax benefits.

Outline

  1. Domicile vs. tax residency
    1. Impact of domicile on business owners
    2. Residency rules and key issues
  2. State regulatory challenges; new allocation and residency issues
  3. Key planning considerations
  4. Strategically relocating to minimize state taxes
  5. Special tax considerations

Benefits

The panel will review these and other key issues:

  • How do domicile and tax residency rules impact estate planning?
  • What are the critical considerations for domicile and estate planning for business owners?
  • What are the critical elements for shifting domicile or residency from one state to another to minimize or avoid high taxes?
  • What are the tax challenges and potential pitfalls to avoid?

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Understand how domicile and tax residency rules impact estate planning
  • Recognize critical tax considerations for domicile and estate planning for business owners
  • Identify the key elements for shifting domicile or residency from one state to another to minimize or avoid high taxes

  • Field of Study: Taxes
  • Level of Knowledge: Intermediate
  • Advance Preparation: None
  • Teaching Method: Seminar/Lecture
  • Delivery Method: Group-Internet (via computer)
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
  • Prerequisite: Three years+ business or public firm experience preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of pass-through taxation, including taxation of partnerships, S corporations and sole proprietorships, qualified business income, net operating losses and loss limitations; familiarity with net operating loss carry-backs, carry-forwards and carried interests.

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).